OPINION
RAUM, Judge:
The Commissioner determined an estate tax deficiency of $10,684.73 against the Estate of Gertrude Hoffman. Several issues have been resolved by agreement of the parties. The remaining dispute concerns property which was subject to administration of the probate estate of Gertrude Hoffman's late husband and which, on completion of administration, was transferred to a testamentary trust established by him of which she was the trustee...
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